We’re seeing lots of requests recently for SMCR training and support and I thought it might be useful to put together some top tips/things to think about for those responsible for this part of the business. There are links for more information below, or drop me and the team a line, for a chat.
The FCA has made it clear that the SMCR plays a significant role in the success, or otherwise of Consumer Duty implementation in individual businesses. This is unsurprising given the emphasis FCA has made all along about Board level engagement on the duty, including a Board level champion for the Duty.
No over or under laps
Ensure that holders of SMFs have discussed and agreed with each when they hand off to one another. This should mean each individual is abundantly clear about when they are personally responsible and when another SMF is responsible. Many SMFs make lots of assumptions in this space and it is important to check and agree each of those assumptions.
Personalised Training and Awareness
Invest in personalised training programs tailored to the roles and responsibilities of each member of staff and about the implications of the SMCR and their individual obligations. Awareness is key to ensuring a culture of compliance throughout the organisation. The FCA also highlights that training should incorporate real-life and interactive situations to help staff easily understand the rules.
3. Update Policies and Procedures
Review and update existing policies and procedures to align with the new requirements of the SMCR. Ensure that documentation is clear, accessible, and reflective of current best practices.
4. Regular Monitoring and Review
Establish a system for regular monitoring and review of SMCR compliance to verify that those procedures are being followed correctly, identify potential issues, and make necessary adjustments.
5. Establish a way of identifying and managing potential breaches
This is crucial for compliance with the conduct rules. The annual window for submitting conduct rules breaches runs from 1 September to 31 October. Submitting blank returns may be received by FCA as an indication that you are not proactively checking your staff’s compliance with the conduct rules. So be prepared to prove that negative - you do not have any breaches to report. Be clear that you are proactively looking and make sure you have a clear and consistent way of reviewing potential breaches that is fair to your people but also for the FCA.
We support and implement SMCR in many banking firms and have learned the good and let’s say not so good practices for success. Here are some of our templates and guides if you’re looking for more insight. Alternatively get in touch for a healthcheck or training for your teams.
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